Free Notice (Other) - District Court of Colorado - Colorado

Case 1:04-cv-01823-PSF-BNB

Document 27

Filed 09/19/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-F-1823 (BNB) GERALD M. HAASE, M.D., Plaintiff, v. JEFFERSON PILOT FINANCIAL INSURANCE COMPANY, Defendant. NOTICE OF DEPOSITION AND REQUEST TO PRODUCE

TO:

CINDY CROFT, MANAGER of DISABILITY CLAIMS, AND COUNSEL OF RECORD

PLEASE TAKE NOTICE that on Tuesday, October 25, 2005, beginning at the hour of 2:00 p.m., or immediately following Mr. Norman Carrier's deposition, if it concludes earlier, counsel for Plaintiff will take the deposition of Cindy Croft, Manager of Disability Claims, Jefferson Pilot Financial, at Jefferson Pilot Financial, Concord, New Hampshire, or at such other location to be specified, before a certified shorthand reporter, until completed, at which time and place your presence is required. YOU ARE REQUESTED TO PRODUCE and have present at your deposition all original documents, correspondence, internal memoranda, claim manuals, electronic files and email activity, including but not limited to, Defendant's original claim and underwriting files. Respectfully submitted this 19th day of September, 2005 . TAFFET LAW, P.C. s/ Steven Taffet _________________________________ Steven Taffet 2305 Broadway Boulder, CO 80304 (303) 449-2830 Attorney for Plaintiff

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Case 1:04-cv-01823-PSF-BNB

Document 27

Filed 09/19/2005

Page 2 of 2

CERTIFICATE OF SERVICE I hereby certify that on September 19th 2005, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addressee. Kevin O'Brien HALL & EVANS LLC 1125 17th Street, Suite 600 Denver, Colorado 80202 s/ Lacy Sorrells
_________________________

Lacy Sorrells

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